IrishCo, a manufacturing corporation resident in Ireland, distributes prod- ucts through a U.S. office. Current-year taxable income from such sales in the United States is $12 million. IrishCo's U.S. office deposits working capital funds in short-term certificates of deposit with U.S. banks. Current-year interest income from these deposits is $150,000.

IrishCo also invests in U.S. securities traded on the New York Stock Exchange. This investing is done by the home office. For the current year, IrishCo records real- ized capital gains of $300,000 and dividend income of $50,000 from these stock investments. Compute IrishCo's U.S. tax liability, assuming that the U.S.-Ireland income tax treaty reduces withholding on dividends to 15% and on interest to 5%. Assume a 34% U.S. tax rate.